BrokerExamThe Registered Insurance Brokers of Ontario (RIBO) completed 60 spot checks of brokerages in its 2024-2025 fiscal year and referred nine of them, 15 percent, to its Investigations Department over significant regulatory concerns. Those are the headline figures in RIBO’s 2024-2025 Spot Check Report, which the May 2026 issue of its newsletter, the RIBO Review, pointed licensees to. RIBO calls the results “a mixed picture” against 2023-2024: compliance with disclosure and Take-All-Comers requirements improved, while auditors found more issues of significant concern that were referred for “fulsome investigations.”
The spot check process
In RIBO’s description, its auditors assess a brokerage’s practices, procedures, policies and operations, give guidance to resolve minor deficiencies, and meet the Principal Broker. Most files close with a letter to the Principal Broker setting out the outcome and any recommendations. Some go to the Investigations Department; RIBO says it escalates on complexity, issue severity, risk criteria and its analysis of the audit facts.
The figures
Every percentage below is RIBO’s, as printed in the report, with the group RIBO measured it against.
| Area | 2024-2025 | 2023-2024, as RIBO states it |
|---|---|---|
| Guidance on minor practice enhancements | 95% of audited brokerages | not given |
| Significant regulatory concerns | 15% of cases (nine of the 60 spot checks referred to Investigations) | not given as a figure |
| Financial reporting | 68% of brokerages received guidance on improving financial reporting and practices | 75% of brokerages found not to have complied with financial requirements |
| Written disclosure records | 75% of brokerages compliant, with written documentation of disclosure in client files | 57% of brokerages without proper written disclosure record keeping |
| Take-All-Comers disclosure timing | 18% non-compliance among reviewed cases | 29% |
| Continuing education records | 31% of the brokerage cases reviewed had no process for monitoring or keeping up-to-date records of licensees’ continuing education (CE) hours | not given |
| Office processes | 11% of brokerages had no written office policies and procedural manuals | not given |
RIBO describes 68 percent as a decrease from 75 percent. As printed, the two figures count different things: brokerages given guidance in 2024-2025, and brokerages found not to comply in 2023-2024. The disclosure figures are also stated from opposite sides: 75 percent compliant in 2024-2025, against 57 percent without proper records in 2023-2024.
Trust money and Position Reports
The report’s list of financial issues includes “90-day credit balances not refunded to clients in a timely manner,” trust bank accounts not designated as trust accounts, trust accounts used for operating purposes, trust deficits, outstanding and inaccurate Position Reports, and shareholder loans left off the report so that equity was overstated or understated.
The report cites no section, but the rules behind several of those items are in O. Reg. 991, s. 16. Subsection (1) requires each trust account to be kept in the member’s name and designated as a trust account. Subsection (4) bars disbursing or withdrawing trust money except on the terms it was received under, while letting a member move money that belongs to the member into the general account. Subsection (6) requires a member to be able to meet all trust obligations at all times from the trust account, trust investments and trust funds receivable, leaving out premiums receivable for more than 90 days. The Position Report is s. 21: a report as of fiscal year-end, filed within ninety days after it, and a second as of six months after year-end, filed within nine months after it.
RIBO lists four steps it has taken or has under way: changes to the online Position Report (Form 1) tool to cut errors, automatic reminders before filing due dates, an educational module on the Position Report, and newsletter articles on common reporting errors.
Disclosure and Take-All-Comers
Some brokerages did not give clients summary quotation sheets, conflict of interest disclosure or commission disclosure letters, and did not keep copies on file. On Take-All-Comers, RIBO says a few brokerages gave disclosure at or before the point of sale instead of at the time of quotation, which the report ties to guidance issued in April 2024. Some files lacked a summary quotation sheet showing all available markets and the lowest available rate, a copy of the CISRO Principles of Conduct for Insurance Intermediaries, or RIBO’s Fact Sheet About Your Registered Insurance Broker.
CE records
Beyond the 31 percent with no process for tracking CE, RIBO reports that in the cases reviewed, recorded CE hours did not match the CE certificates. By-Law No. 3, s. 7.1 (a), requires each individual licensee who is not a Principal Broker, Deputy Principal Broker or Supervising Broker to complete the accredited hours set by Council, or by its delegate, on or before September 30 and in each 12-month period after, and s. 7.1 (d) suspends the registration of a licensee who fails to, unless exempted.
The nine referrals
Among the issues in the nine referred files, RIBO lists disclosure not given to clients (the CISRO Principles and the RIBO Fact Sheet), trust funds deposited into the general account instead of the trust account, operating in a trust deficit, books and records not properly prepared or kept, and failure to comply with the Take-All-Comers Rule.